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Conflicts of Interest

Research Integrity

Conflict of Interest (COI) relates to financial or other interests or relationships that compromise, have the potential for compromising, or may have the appearance of compromising an employee’s objectivity in fulfilling their university duties or responsibilities. UNCW utilizes three disclosure forms described below that are stipulated by UNCW policy and are required for all full-time, part-time, and temporary faculty and EHRA non-faculty staff who are senior/key investigators on externally funded research projects. You can learn more about UNCW's COI policy here.

The COI team in the Research Integrity Office (RIO) coordinates UNCW's COI compliance efforts. RIO offers all operations virtually. We look forward to assisting you.

Submitting COIs

Annual Conflict of Interest Disclosure

Annual Conflict of Interest (COI) disclosures may be submitted in OSPREY at any time. The Provost will announce the official submission deadline after the fall semester begins. Employees are encouraged to submit their disclosures early.

Who is required to submit?
All faculty and EHRA non-faculty employees must complete an annual COI disclosure, including full-time, part-time, permanent, and temporary employees, as well as faculty on phased retirement.

Certain SHRA employees are also required to submit a disclosure if they teach a course or serve in an interim EHRA position.

Additional information about the annual disclosure requirement is provided below.

Employees who have not submitted their disclosure by the deadline will receive reminders until it is completed.

Quick instructions on how to submit your annual COI disclosure are below. If you would like to schedule a meeting for help submitting your annual COI form, please contact the COI staff at coi@uncw.edu.

Quick Question? COI Office Hours via Zoom, Thursdays 10-11 am

Annual COI Disclosures

All faculty and EHRA non-faculty employees must complete an annual conflict of interest disclosure through our online disclosure management system, OSPREY, to report their activities, interests, and relationships or lack thereof. Certain SHRA positions are also subject to this requirement if an SHRA employee teaches a course or serves in an interim EHRA position.

Employees subject to this requirement include full-time and part-time, permanent and temporary, research-active and not-research-active, faculty, EHRA non-faculty, and certain SHRA positions (those who teach classes or serve in interim EHRA positions), as well as faculty who are on phased retirement. Employees who are subject to this requirement must submit a disclosure annually even if they have no activities to report, their previously reported activities have not changed, or they already have an approved management plan in place for previously reported activities.

This requirement is in addition to disclosures submitted for specific funded projects.

Quick guide to submit an Annual COI Disclosure:

  1. Log in to OSPREY
  2. Click Conflict of Interest on the left navigation menu of the OSPREY Home screen
  3. Click Create/Update Disclosure
  4. Find the first row of buttons under your contact information and click Create or Update ANNUAL Disclosure
  5. Instructions are provided throughout the form for your reference
  6. Complete all questions and click the Click to Lock and Submit button when ready to submit

Need more resources?

Please email coi@uncw.edu to request step-by-step instructions with screenshots or to schedule a Zoom session for a demonstration or hands-on assistance.

External Professional Activities for Pay

An External Professional Activities for Pay (EPAP) is defined as any activity that is not included within an employee's UNCW responsibilities, is undertaken for compensation by a non-UNCW entity, and is based upon the professional knowledge, experience, and abilities of the employee.

Requests for approval to engage in an EPAP must be submitted at least ten (10) days prior to engaging in the activity. When subject employees report EPAPs in OSPREY, the request is routed to the employee's supervisor for approval. If the request is denied, per UNCW policy, the employee has the right to appeal the decision.

If you are a supervisor and you receive a notice informing you that an employee under your supervision has submitted an EPAP for your review, please log into OSPREY to conduct the review.

Quick guide to submit an EPAP:

  1. Login to OSPREY
  2. Click Conflict of Interest on the left navigation menu of the OSPREY Home screen
  3. Click Create/Update Disclosure
  4. Find the second row button under your contact information and Click Disclose EPAP
  5. Instructions are provided throughout the form for your reference
  6. Complete all questions and click the Click to Lock and Submit button when ready to submit

Differences Between Annual & EPAP

It's not necessary to disclose an activity on both the annual COI and EPAP forms.

The annual COI disclosure form is used to report activities or relationships that you or a member of your family have with non-UNCW entities whose operations are related or potentially related to your university responsibilities. These activities or relationships may be paid or unpaid, and the main concern is determining if the activity/relationship introduces bias, has the potential to introduce bias, or has the appearance of introducing bias into university decisions and duties. Disclosure forms that indicate an activity or relationship are initially reviewed by COI staff and are forwarded to the discloser's supervisor as needed for a determination.

The Notice of EPAP is used to seek approval from the discloser's supervisor of an upcoming paid professional activity. Unlike relationships with entities reported on annual COI disclosure forms, the non-UNCW entity contracting an EPAP has no association with UNCW. This often occurs when UNCW faculty are hired to perform consulting work by local governments, public schools, or other organizations unassociated with UNCW. 

Project-Specific COI Disclosures

When conducting funded research at UNCW, there is a requirement for researchers to disclose the financial or other interests related to the funded project and complete mandatory training on financial conflict of interest. When investigators submit proposals through OSPREY, they will be contacted by RIO staff on any compliance requirements that need to be met, including information on how to submit a disclosure form that is specific to the funded project.

Project-specific disclosures are submitted through OSPREY.

Quick guide to submit a Project-Specific COI Disclosure:

  1. Login to OSPREY
  2. Click Conflict of Interest on the left navigation menu of the OSPREY Home screen
  3. Click Create/Update Disclosure
  4. Find the third row button under your contact information and Click Disclose Project
  5. Be sure to click Add Project to identify the project to which the disclosure pertains.
  6. Instructions are provided throughout the form for your reference
  7. Complete all questions and click the Click to Lock and Submit button when ready to submit

Training & Quiz Completion Requirements

Every investigator on funded projects, including sub-recipient investigators, are required to complete conflict of interest training prior to engaging in externally-funded research. The COI training must be completed at least every four years. If you are unsure of when your training needs to be updated, please contact COI staff.
Complete Your Training

Federal Regulation on COI in Funded Research

Specific conflict of interest training and reporting requirements may be required when UNCW investigators apply for and/or receive funding from certain federal agencies, including the Public Health Service (PHS) Awarding Components (includes NIH and SAMHSA), the National Science Foundation (NSF), the U.S. Department of Justice (DOJ), and the U.S. Department of Energy (DOE). UNCW will comply with these requirements.

The U.S. Department of Health and Human Services issued the final rule that amends the Public Health Service (PHS) regulations on Responsibility of Applicants for Promoting Objectivity in Research for Which PHS Funding is Sought [PDF] (45 C.F.R. Part 50) and Responsible Prospective Contractors (45 C.F.R. Part 94).

The National Science Foundation (NSF) updated its Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 23-1) on January 30, 2023, that includes NSF's conflict of interest policies in Chapter IX: Recipient Standards.

The Department of Justice requires in its Grant Application Resource Guide recipients and subrecipients of funding to have conflict of interest policies in place and either certify that they have identified no personal, financial, or organizational conflict of interests that could affect the independence or integrity of the research, including the design, conduct, and reporting of the research or provide a specific description of the conflict(s).

The Department of Energy issued an interim Conflict of Interest Policy Requirements for Financial Assistance on December 20, 2021, that largely aligns with the PHS policy linked above.

 

Organizational COI

UNCW is committed to identifying, avoiding, and managing actual or perceived conflicts of interest relating to its research activities consistent with federal laws and regulations. In conducting federal research and contracting activities, university members have a responsibility to comply with this guidance.

A unique type of conflict of interest may arise when members of UNCW assist in the development of new federal programs or federal contract specifications, and UNCW later competes for federal support through those new programs or contracts. This type of conflict of interest has been named “Organizational Conflict of Interest” (OCI) and is described in Federal Acquisition Regulation (FAR) Subpart 9.5, “Organizational and Consultant Conflicts of Interest."

Federal agencies often invite university faculty members to provide advice and technical assistance. Such public service is part of UNCW’s mission and is encouraged. However, there may be the potential for an OCI in such cases. For example, if a faculty member is on a panel that provides input for a new Request for Applications that will be put forth in the future, an OCI may exist if UNCW then submits an application. Although the important contributions that faculty members and other UNCW personnel may make in advising federal agencies must not be discouraged or diminished, any OCI must be managed.

UNCW seeks to identify and manage OCI in a manner consistent with FAR Subpart 9.5. This guidance applies to all university members, to include faculty, staff, and students.

Appeals

A covered employee may appeal a supervisor’s decision regarding conflicts of interest and conflicts of commitment (external professional activities for pay). The covered employee shall not proceed with the proposed activity but may appeal that decision to the administrative officer to whom the department chair or other supervisor reports (e.g., dean) and then, if needed, to the chancellor or the chancellor’s designee.

Appeals must be made in writing within five (5) business days of receipt of the decision to be appealed. For appeals related to conflicts of interest or commitment, the covered employee bears the burden of demonstrating to the officer’s satisfaction that the activity at issue is not a conflict of interest or commitment or that it can be managed differently.

A decision on any such appeal shall be given by the administrative officer, or the chancellor or chancellor’s designee, as appropriate, to the covered employee within ten (10) business days of the date on which the appeal is received. The decision of the chancellor or the chancellor's designee is final.

Feedback

Tell the COI team in the Research Integrity Office how we're doing on this quick, 4-question survey!

Additionally, please be aware that the Office of Internal Audit at UNCW provides links for reporting allegations of fraud, waste, abuse, or mismanagement of funds. Click on the link below to report concerns.

Report Fraud

Resources

Contact Us

Conflict of Interest (COI)

Phone: 910.962.7774

coi@uncw.edu

Institutional Official

Dr. Stuart Borrett

910.962.7430